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Stephen Warshaw v HMRC [2020] UKUT 366

Tax Cases and Appeals Crown Copyright
2020-12-23
Entrepreneurs’ relief – “personal company” – whether a 10% cumulative preferential dividend which is compounded for unpaid dividends is a dividend “at a fixed rate” – no, therefore shares carrying such rights are ordinary share capital – appeal dismissed
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HMRC v S Warshaw [2020] UKUT 366

Tax Cases and Appeals Crown Copyright
2020-12-23
CAPITAL GAINS TAX – entrepreneurs’ relief – “personal company” – whether a 10% cumulative preferential dividend which is compounded for unpaid dividends is a dividend “at a fixed rate” – no, therefore shares carrying such rights are ordinary share capital – appeal dismissed
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Gallaher Ltd v HMRC [2020] UKUT 354

Tax Cases and Appeals Crown Copyright
2020-12-11
Whether the UK legislation in relation to intra-group disposals is compliant with EU law – the applicable freedoms, whether or not the provisions in question restrict a freedom – whether or not any restriction can be justified – proportionality of restrictions – conforming interpretation and disapplication – consideration of movements of capital – whether to refer questions of EU law to the Court of Justice of the European Union
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Volkerrail Plant Limited v HMRC [2020] UKFTT 476

Tax Cases and Appeals Crown Copyright
2020-11-16
Whether s 403D(1)(c) Income and Corporation Taxes Act 1988 unlawful restriction on freedom of establishment – If so, whether it should be disapplied or a conforming construction applied – Appeals allowed
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Executors of the late Sheriff G L Cox v HMRC [2020] UKFTT 442

Tax Cases and Appeals Crown Copyright
2020-11-03
INHERITANCE TAX – Business Property Relief – s 104 and s 105 of Inheritance Tax Act 1984 – furnished holiday letting business – whether relevant business property – whether business wholly or mainly of making or holding investments – appeal dismissed
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Hamish Taylor v HMRC [2020] UKFTT 416

Tax Cases and Appeals Crown Copyright
2020-10-17
INCOME TAX – ALLOWABLE EXPENSES – Closure Notice — Penalty – Subcontractor staying away from home for 165 days – business base – Section 34 Income Tax (Trading & Other Income) Act 2005 “Wholly and exclusively” – appeal against Closure Notice dismissed – appeal against Penalty Notice allowed
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Aozora GMAC Investments Ltd v HMRC [2021] UKFTT 99

Tax Cases and Appeals Crown Copyright
2020-10-08
HMRC was incorrect in disallowing credit under s790 of the Income and Corporation Taxes Act 1988 (ICTA 1988) for US withholding tax suffered on interest paid to Aozora GMAC Investments Ltd, a UK-resident company (“the appellant”), on loans that it had made to its US subsidiary
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